20070629Memorandum in support of petition.pdf

John R. Hammond, Jr., ISB No. 5470
FISHER LAW GROUP, LLP
U S Bank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
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Attorneys for Avimor, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROV AL OF
AN AGREEMENT BETWEEN A VIMOR, LLC
AND IDAHO POWER TO PROVIDE ELECTRIC
TRANSMISSION AND SUBSTATION
FACILITIES TO THE AVIMORMULTI-USE DEVELOPMENT
Case No. IPC-06-
MEMORANDUM IN
SUPPORT OF PETITION
FOR
RECONSIDERATION OF
COMMISSION FINAL
ORDER NO. 30322
COMES NOW Avimor, LLC, an Idaho limited liability company, by and through
its attorneys of record, Fisher Law Group, LLP, and pursuant to Idaho Public Utilities
Commission Rules of Procedure 331 and Idaho Code ~ 61-626, files this Memorandum
in support of Avimor, LLC's ("Avimor" or the "Company ) previously filed Petition for
Reconsideration (the "Petition
In general, Avimor asserts that Final Order No. 30322 is unreasonable, unlawful
erroneous, unduly discriminatory and not in conformance with the facts of record and/or
applicable law. Specifically, Avimor contends:
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 -
The Commission s rationale for denying the Special Facilities
Agreement, that it will place a great financial burden and undue risk on existing
ratepayers, is not supported by substantial and competent evidence in the record.
The Commission s findings in Order No. 30322 discriminate
against Avimor in violation of Idaho Code ~ 61-315 , and also violates the Equal
Protection Clause of the United States and Idaho Constitutions; and
New information provided to Avimor as a result of the filing ofIdaho
Power Company s ("IPCo ) new rate case, Case No. IPC-07-, shows that the
average per customer connection cost for transmission and substation equipment cost is
now $1 100.00.
Avimor also requests that the Commission clarify or amend Order No. 30322 to
allow it to receive refunds based not only on the number of residential connections, but
also upon the kva ratings of the distribution transformers serving non-residential
connections.! Staff did not oppose this feature of the Special Facilities Agreement (the
SF A") and A vimor believes that the Commission intended that this was allowable, but
the language in the Discussion section of Order No. 30322 does not expressly address the
Issue.
ARGUMENT
The Commission s sole reason for denying approval of the Special
Facilities Agreement and the alternate proposal made by Avimor in its Reply Comments,
that is that either will place a great financial burden and undue risk on existing ratepayers,
is not supported by substantial and competent evidence in the record.
1 For example, A vimor s wastewater treatment plant falls into this category.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 2
In Order No. 30322 at p. 1 , the Commission found "(b )ased on the record
presented, the Commission has determined the Special Facilities Agreement as written
places too great a financial burden on Idaho Power s existing ratepayers, and the
Commission accordingly denies approval of the Special Facilities Agreement as filed.
A review of the record demonstrates that there is a lack of substantial and competent
evidence in the record to justify the Commission s rejection of the SF A and A vimor' s
alternate proposal based on these grounds.
A vimor has offered evidence in the record regarding potential rate impacts that
could result from approval of the SF A as originally written stating:
(T)he Project's overall impact on IPCo s entire customer base if the
payments are refunded to A vimor is very small. If the Commission were
to accept the original rSFA1, which Avimor is not proposing,Avimor were
to receive a full refund of the payments and IPCo were to file a general
rate case every year where the Commission authorized inclusion of the
cost of the refund payments to the Utility into rates the impact on
customer rates would be 0.01 % per year for 10 years, creating an overall
impact of 0.1 % when the full cost of the Facilities was authorized to be
included in rates. After the recovery of all refunds and their inclusion in
rates, any additional customers in that area would connect to the system at
little or no cost for IPCo and its ratepayers. In fact, additional connections
may provide downward pressure on rates because the transmission and
distribution substation equipment would already be paid for. Under
A vimor' s Proposal, the negligible rate impacts of the rSF A 1 will be further
mitigated.
Avimor Reply Comments at p. 8-9 (emphasis added). No party disputed the results of
Avimor s rate impact calculation or the fact that this impact would be further mitigated if
A vimor' s alternate proposal were adopted, that is to base a full refund of the advance
upon the connection of 1 103 customers for recovery of its advance rather than 685 , as
proposed in the original SFA. Avimor still believes its alternative proposal is sound and
will mitigate any minimal increase in customer rates, if at all, over a period of years, at
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 3
which time IPCo will have new customers to help recover the cost of the new
infrastructure investment.
While it is true that Avimor does not dispute Staffs calculations regarding
the per customer investment for similar facilities, the Company does not agree
that these figures should be the sole measure of establishing a refund amount for
the SF A.
First, it is patently unfair to the Company to compare the SF A refund
amount as proposed by A vimor in its Reply Comments to the average currently
embedded in rates. This is because the later figure is significantly depreciated and
includes all utility connections prior to 2003. As such, it does not accurately
reflect the current average cost which IPCo is incurring to connect new customers
today. This is clearly shown by the Commission s recognition that this average
rose to $1 000., as calculated from IPCo s last two rate cases. As will be
discussed later, this average cost continues to rise. Even though this average cost
per customer for transmission and distribution substation equipment provides a
reference point for the Commission to consider, it still is an average of
connections to IPCo s system which are both higher and lower than $1 000.00.
As such, there should be no dispute that current customer rates as authorized by
the Commission include connection costs for transmission and distribution
substation equipment which exceed this average. An example of this is the
Commission s inclusion of higher transmission and distribution substation
equipment costs in rates as a result of the Hidden Springs special facilities
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 4
agreement. To not allow similar treatment is simply not consistent with the
Commission s past and current practices.
Finally, as argued in the Company s Reply Comments, virtually all new
equipment IPCo purchases, whether for a development such as A vimor or for any other
need, will cause at least some upward pressure on rates because it is more expensive than
older, partially depreciated equipment. Under Commission s rationale logically played
out, if IPCo needs equipment that is more expensive than older, depreciated equipment
already in rates, the utility would only be allowed to recover up to the average amount
already in rates. As a result, IPCo would not be able to recover its costs and would be
hard-pressed to make the appropriate investments to keep its system functioning properly.
In addition, establishing a precedent that the refund amount for advances in these
situations should be set at an average cost likely insures that other developments or
connections whose per connection cost for transmission and distribution substation
equipment is lower than this average will demand to receive a refund of their advance at a
higher rate, thus accelerating rate impacts.
Based on the foregoing, there is no substantial and competent evidence in the
record showing there will be an undue burden placed on all ratepayers if the SF A is
approved.
The Commission s findings in Order No. 30322 discriminate
against Avimor in violation of Idaho Code & 61-315, and also violates the Equal
Protection Clause of the United States Constitution and as such, the Commission
has not regularly pursued its authority.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 5
The Commission did not discuss A vimor' s discrimination and Equal Protection
argument in the Discussion section of Order No. 30322. However, it did mention this
argument in the IPCo Reply Comment section of the Order. IPCo argued that the SF
terms impose a non-recurring charge on A vimor to offset the costs of the utility s capital
investments required to deliver electricity to the A vimor development and that the Idaho
Supreme Court in Idaho State Homebuilders v. Washington Water Power 107 Idaho 415
419 690 P. 350 (1984) specifically stated that it's holding there did not involve a
situation where " non-recurring charge is imposed upon new customers because the
service they require demands an extension of existing distribution or communication
lines and a charge is imposed to offset the cost of the utility s capital investment."
The Commission has broad authority to regulate and fix the rates and charges
assessed by Idaho s public utilities for services. Idaho Code ~ 61-502; Building
Contractors Association v. IPUC 128 Idaho 534, 538 , 916 P.2d 1259 (1996). Idaho
Code ~ 61-301 requires that all rates and charges must be just and reasonable.
conjunction with this Idaho Code ~ 61-315 prohibits either preferential or discriminatory
treatment of ratepayers by public utilities stating:
No public utility shall, as to rates, charges, service, facilities or in any
other respect, make or grant any preference or advantage to any
corporation or person or subiect any corporation or person to any
preiudice or disadvantage No public utility shall establish or maintain any
unreasonable difference as to rates, charges, service, facilities or in any
other respect, either as between localities or as between classes of service.
2 In Case No. UWI-07-, Order No. 30345 , the Commission also opined that it was not determining
fees or rates to be paid by utility customers in this case and thus Idaho State Homebuilders v. Washington
Water Power 107 Idaho 415, 419, 690 P. 350 (1984) was not applicable. To the extent this same reasoning
applies to the instant case it simply does not make sense as the Commission and its Staff have clearly based
their decisions upon what impact the SF A will have on customer rates and attempted to use the
Commission s ratemaking authority to justify the result. A vimor is clearly a utility customer ofIPCo by
virtue of the SF A. In addition, A vimor will be purchasing power from IPCo for its waster water treatment
facility and other buildings in the development it will own.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 6
The commission shall have the power to determine any question of fact
arising under this section.
Idaho Code ~ 61-315 (emphasis added). See also, Idaho Code ~~ 61-301 (requiring
imposition of only just and reasonable charges by utilities); 61-502 (authorizing the
Commission to correct unjust or preferential rates); Utah-Idaho Sugar v. Intermountain
Gas Co.100 Idaho 368 , 597 P.2d 1058 (1979). Not all differences in a utility s rates and
charges as between different classes of customers constitute unlawful discrimination or
preference under ~ 61-315. A reasonable classification of utility customers may justify
the setting of different rates and charges for the different classes of customers. Utah-
Idaho Sugar Co. v. Intermountain Gas Co., supra. Any such difference (discrimination)
in a utility s rates and charges must be justified by a corresponding classification of
customers that is based upon factors such as cost of service, quantity of electricity used
differences in conditions, economy of operation and the actual differences in the situation
of the consumers for the furnishing of the service. Utah-Idaho Sugar Co.
Intermountain Gas Co., supra. The Court has stated that it has not found one criterion to
be necessarily more essential than another. Nor did it find the criteria as listed above as
being exclusive stating:
Each case must depend very largely upon its own special facts and every
element and every circumstance which increases or depreciates the value
of the property, or of the service rendered, should be given due
consideration, and allowed that weight to which it is entitled. It is, after
all, very much a question of sound and well-instructed judgment. (citation
omitted).
Kiefer v. City of Idaho Falls 49 Idaho 458, 467, 289 P. 81 , 84 (1930)(emphasis added).
In Agricultural Products Corporation v. Utah Power Light Company, 98 Idaho 23 , 557
P.2d 617 (1976) the Court elaborated on this stating:
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 7
Under the procedure we adopt here, a determination of undue
discrimination or preference must first be made in a rate proceeding
wherein all pertinent factors are considered including, among others, the
provisions of the special contract, the relationship between the contracting
parties, the cost of service, the financial condition of the utility, and the
effect of contract rates on other customers.
In the Homebuilders case, Washington Water Power requested approval for a
seasonal commodity rate that would serve as a signal to all electric customers regarding
the utility s higher cost of resource supply in winter and thus encourage energy
conservation. 107 Idaho at 417 690 P.2d at 352. The Commission reiected this proposal
in favor of a one-time, non-recurring contribution charge of $50.00 per installed kilowatt
of cavacity for all new customers who used electricity for space heating Id. at 418, 790
P.2d at 353 (emphasis added). Because this charge would result in a typical contribution
charge of between $1 000.00 and $2 000.00 per new residential customer, the Idaho State
Homebuilders Association petitioned to intervene in the case and ultimately appealed the
Commission s Order. Id.
In its decision, the Idaho Supreme Court concluded that the contribution charge
unlawfully discriminated between Washington Water Power s "new" and "old"
customers, rejecting the notion that only "new" customers are responsible for the level of
resource demand in the winter months. Id. at 421 690 P.2d at 356. Although the record
established that increased demand necessitated an increased reliance on more expensive
resources, the Court concluded that the resultant increased costs did not equate with a
difference in criteria of cost of service or difference in condition of service as between
the two classes.Id. Further, the Court reasoned that since the charges were only
imposed on new customers, the Commission evidently assumed that only "new
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 8
customers were responsible for the level of demand, but that premise has no basis in
either the record or in economic theory. Id.
In the Building Contractors case, the Court reviewed a portion of a general rate
order by the Commission, which increased the amount of hook-up fees Boise Water
Corporation ("Boise Water ) may charge for new connections to its water service system
from July 25 , 1994, forward. The Building Contractors maintained that the hook-up fees
approved by the Commission unlawfully discriminated against Boise Water customers
connecting new service on or after July 25 , 1994, based on the fact that the new hook-up
fees allocate the entire incremental cost of new resource plant construction to new
customers. The old fees did not contain incremental or marginal capital investment costs
of new plant construction. This new allocation they argued was premised on the flawed
idea that only new customers are responsible for increased resource demand.
In its decision, the Court noted that similar to Homebuilders the pattern, nature
and time of Boise Water customers' usage did not change on July 25, 1994, nor did the
conditions of service. Similarly, the quantity of water used by Boise Water s individual
customers before July 25 , 1994, does not differ from the quantity used by individual
customers added to the system after that date. Id. The Court further reasoned that while
it is true that the cost of service has increased, the cost has increased proportionately for
each Boise Water customer and there is no difference in the cost of service between
customers who connected to Boise Water s system before July 25 , 1994, and those who
have connected or will connect to the system from that date forward. The Court further
noted that each new customer has contributed to the need for new facilities and that to the
extent that the new hook-up fees are based on an allocation of the incremental cost of
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 9
new plant construction required by growth and by the Safe Drinking Water Act solely to
new customers, the fees unlawfully discriminate between old and new customers in
violation of Idaho Code ~ 61-315.
It seems the Commission s reasoning for not recognizing that the Building
Contractors and Homebuilders cases are not applicable is based on dicta from the Court
in the Homebuilders decision. Although not an issue before the Court in that case it
stated
, "
the instant case presents no factors such as when a non-recurring charge is
imposed on new customers because the service they require demands an extension of
existing distribution or communication lines and a charge is imposed to offset the cost of
the utility s capital investment." Homebuilders 107 Idaho at 421 690 P.2d at
First, as the issue described above from the Homebuilders case was not squarely
before that Court and was merely a situation it offered comment on, it is uncertain what
its decision would be on such an issue as the Court has recognized that each case depends
largely on its own facts. See Kiefer v. City of Idaho Falls 49 Idaho 458, 467, 289 P. 81
84 (1930); Agricultural Products Corporation v. Utah Power Light Company,
Idaho 23, 557 P.2d 617 (1976). Thus, even were the above factual situation present, the
Court would look beyond the nature of the extension to additional factors to determine
whether discrimination or preference was resulting. Id. See also Utah-Idaho Sugar Co.
v. Intermountain Gas Co., supra
Second, the Avimor/IPCo SFA does not involve a "non-recurring charge." A
charge is defined as "the price of, or rate for, something.Black's Law Dictionary.
Black's Law Dictionary also generally describes a rate in the public utilities context to
mean "a charge for a service open to all and upon the same terms." Avimor is not being
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 10
charged or being required to contribute funds as a charge for the construction of
infrastructure under the SF A. Rather, it is advancing the costs for construction with the
opportunity for refund. Refund amounts will be included in rates which will affect
A vimor as a ratepayer. As such, A vimor asserts that not only is the advance ultimately
going to be charged to A vimor as a ratepayer, but also the advance and refund
mechanisms of the SF A are conditions upon which A vimor will receive services and
facilities necessary for such service. This treatment was provided for in the SF A to be
consistent with IPCo s Rule H. Rule H provides that in cases of new connections to the
system an applicant for service may be required to advance costs to complete such
connection. The applicant then has an opportunity to obtain a refund as a "Vested
Interest Holder " which under Rule H "is an entity that has paid a refundable Line
Installation Charge to the Company for a Line Installation.I.P.UC No. Tariff 101
Original Sheet H-(June 1 2006). To the extent the Court's statement regarding
extensions of service in Homebuilders is construed as controlling to that particular
situation, it simply does not apply to this case as Avimor has made an advance with the
opportunity for refund and not paid a one-time charge or contribution with any
opportunity to recoup its funds. Avimor asserts that it is possible that the facts in this
case may present a case of first impression. As such, it cannot be answered with certainty
whether the Court would extend the dicta in Homebuilders to this case. What is certain is
that the ability of the Commission to treat "new" customers differently from "old"
customers is subject to substantial legal doubt as demonstrated by the Homebuilders and
Building Contractors cases.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 -
In this case, A vimor is clearly a "new" customer of IPCo by virtue of the terms of
the SF A. Further, it is undisputed that A vimor' s relationship as a customer to IPCo will
continue as it will connect as a customer to the new infrastructure and purchase energy
from the utility for its waste water treatment plant, commercial and retail facilities in the
development and further facilities to maintain the development.
The failure to accord A vimor the same or similar treatment as old customers
demonstrates that the Commission is not recognizing the fact that IPCo has undoubtedly
added new connections to the system involving transmission and distribution substation
equipment which are above and below the average cost cited by the Commission.
stated previously, it is undisputed that these costs above and below the average have been
included in customer rates. This is clearly demonstrated by the Hidden Springs special
facilities agreement. This fact is illustrated by the Hidden Springs special facilities
agreement where the developer agreed to advance the entire cost for the design and
construction of the distribution substation equipment with the opportunity to receive
refunds from IPCo. According to IPCo, the per customer investment for this distribution
substation equipment was approximately $2 333 per customer.3 Hidden Springs was
eventually refunded its entire advance at a rate of $2 333 per customer connection, which
refunds were authorized to be included in rates by the Commission in 2004. See Order
No. 29505, Case No. IPC-03-13.4 It is safe to assume that if the Hidden Springs
3 IPCo response to Avimor Request No.4: "The approximate cost of the Hidden Springs substation
construction project was $700 000. At an estimated average electrical load often average kilowatts, the
three megawatt station would serve about 300 homes (provided there was no non-residential load served).
Under these assumptions, the cost per home of that project was $2 333.4 Email from Tim Tatum, IPCo Company Analyst, dated March 20 2007
, "
(uJnder the agreement between
Hidden Springs and IPCo, Hidden Springs was required to pay the full construction cost of the substation
over two payments, both issued in 1998. As the subdivision phases were completed, Hidden Springs
ultimately received full reimbursement of its original financial contribution. The total cost of the Hidden
Springs substation was subsequently included into rate base for the purpose of determining customer rates.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 12
facilities were built today, the electrical distribution substation costs would be more
expensive than in 1998.5 Based upon foregoing, it is clear that based on its past practices
the Commission should consider strongly allowing A vimor to receive a refund amount
higher than the average cost per connection for transmission and distribution substation
equipment. The Hidden Springs case provides the Commission with guidance with what
a reasonable refund amount could be for a similar development. Based on the foregoing,
the Commission could and should at least authorize Avimor to recover $2 300 per
customer connection for distribution substation equipment as no reason is given for any
different consideration in this case.
In addition Idaho Code ~ 61-315 provides specifically that:
No public utility shall, as to rates, charges, service facilities or in any
other respect, make or grant any preference or advantage to any
corporation or person or subject any corporation or person to any
prejudice or disadvantage.
Idaho Code ~ 61-315 (emphasis added). The Commission s decision to treat terms for
the provision of facilities to the Avimor development radically differently than that of the
Hidden Springs agreement and the general reality that there are many connections
currently in IPCo s rates that are higher than $1 000.00 is unjustified. Other than its
claim that it will place an undo burden on existing ratepayers, which clearly is not
demonstrated by the evidence in this case, the Commission has cited no reason to treat
A vim or differently based upon other factors, such as quantity of electricity used
differences in conditions, economy of operation and the actual differences in the situation
ofthe consumers for the furnishing of the service. As such, Avimor respectfully
5 Using a CPI increase in costs of3% per year this cost would have been more than $3 000 in 2007.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 13
questions the Commission s legal authority to deny approval ofthe SFA or Avimor
alternate proposal. 6
New information has been provided to Avimor as a result of the filing of
Idaho Power Company s ("IPCo ) new rate case, Case No. IPC-07-08, showing that
the average per customer connection cost is now $1,100.00.
As a result of IPCo ' s new rate case, the utility was able to provide A vimor with
an updated average cost figure for transmission and distribution substation equipment per
customer. This information has been reviewed by Alden J. Holm, a certified public
accountant and licensed to practice in the State of Idaho. See Affidavit of Alden J Holm.
Mr. Holm s conclusion is that based on the same methodology Staff has used to calculate
the average cost of$l OOO., IPCo s new calculation of$l lOO.OO is accurate. At a
minimum, if the Commission decides that the refund amount under the SF A should be
based on IPCo s average per customer cost for transmission and distribution substation
equipment per customer, it should use the more updated average of $1 100 as provided by
IPCo and discussed in the Affidavit of Alden J. Holm.
REQUEST FOR RELIEF
Based on the foregoing, A vimor respectfully requests that the Commission grant
A vimor' s Petition for Reconsideration and allow the SF A to contain the refund
provisions which are proposed by Avimor s Reply Comments. In the alternative, Avimor
requests that the Commission raise the refund amount to be allowed under the SF A to
100.00 to more accurately reflect the average costs which IPCo is currently incurring
per residential customer for transmission and distribution substation equipment.
6 In addition, to Avimor s argument regarding discrimination it also asserts that the Commission s decision
violates the Equal Protection Clause of the United States and Idaho Constitutions as the Commission is
treating Avimor differently than it has others similarly situated.
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 -
Finally, Avimor also requests that the Commission clarify or amend Order No.
30322 to allow it to receive refunds based not only on the number of residential
connections, but also upon the kva ratings of the distribution transformers serving non-
residential connections.
DATED This 29th day of June, 2007.
FISHER LA W GROUP, LLP
ond, Jr.
r Avimor, LLC
MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY That on this 29th day of June, 2007, I caused to be
served the foregoing upon all parties of record in this proceeding as indicated
below:
Jean Jewell
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
P. O. Box 83720
Boise, Idaho 83720-5983
ijewel~puc.state.id.
Monica B. Moen
IDAHO POWER COMPANY
P. O. Box 70
Boise, Idaho 83707-0070
mmoen~idahopower.com
Weldon Stutzman
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
P. O. Box 83720
Boise, Idaho 83702-5983
W eldon.stutzman~puc.idaho.gov
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MEMORANDUM IN SUPPORT OF PETITION FOR RECONSIDERATION OF
COMMISSION FINAL ORDER NO. 30322 - 16